State of Connecticut v. Scott Salamon

Summary

The Supreme Court of Connecticut accepted the defendant's invitation to reconsider its kidnapping jurisprudence and overruled the longstanding rule that a kidnapping conviction may rest on a restraint that is merely incidental to the commission of another crime, holding instead that kidnapping requires an intent to prevent the victim's liberation for a longer period of time or to a greater degree than the underlying crime necessitates. Because the jury was instructed under the superseded precedent, the kidnapping in the second degree conviction was reversed and the case remanded for a new trial on that count, while the convictions of unlawful restraint in the first degree and risk of injury to a child were affirmed against the defendant's claims of prosecutorial impropriety and a constitutionally deficient instruction on intent.